Just like clockwork, the start of a new year brings two important Occupational Safety and Health Administration (OSHA) recordkeeping requirements that printing operations must be aware of and comply with if they qualify. These involve the completion, posting and submission of certain separate, but related, recordkeeping forms. The two key dates are February 1 and March 2.
Meeting these requirements is especially important with the renewed focus on OSHA compliance. Even though there is a new administration, OSHA will still be enforcing its regulations. This means printing operations need to be diligent in meeting their recordkeeping and reporting obligations.
Posting Form 300A (Due February 1)
The February 1 filing date addresses the need to post OSHA’s Form 300A, known as the Summary of Work-Related Injuries & Illnesses. Throughout the calendar year, OSHA requires companies with more than 10 full-time, part-time, or temporary employees to complete and maintain Form 300 known as the Log of Work-Related Injuries and Illnesses. This is to be completed for each work-related recordable injury and illness or fatality occurring in the workplace. For injuries, any incident resulting in medical treatment beyond first aid, as defined by the regulation, constitutes a recordable incident, and must be entered in Form 300. OSHA has a specific list of first aid activities that should be reviewed prior to entering an injury to understand what does not require recording on Form 300.
At the end of each year, all Form 300 entries are to be totaled, and the summary of the information is to be recorded on Form 300A known as the Summary of Work-Related Injuries & Illnesses. In addition to the summation of the workplace injuries and illnesses recorded during the previous calendar year, Form 300A must include the total hours worked that year by all employees covered by OSHA Form 300.
Once completed, Form 300A must be “certified” with the signature of a responsible company official (e.g., owner, officer of the company, or the highest-ranking company official at the establishment) and posted no later than February 1 in a conspicuous place where employee notices are customarily posted. It must remain posted through April 30.
A Form 300 is required to be completed and a Form 300A posted even if there were no recordable injuries or illnesses in the previous year. This is a common mistake that needs to be avoided because during an OSHA inspection, a compliance officer may request to see the previous 5 years of Form 300.
Annual Injury and Illness Reporting (Due March 2)
OSHA's injury and illness reporting requires any printing operation that has, or had at any time last year, more than 20 full-time, part-time, or temporary employees to electronically submit their Form 300A data to OSHA. If a printing operation exceeds the employee threshold, reporting is required even if no recordable injuries were logged in the previous year. The deadline for reporting is March 2, 2025, for the 2024 data.
To allow employers to report this data, OSHA created the Injury Tracking Application (ITA). The web-based form allows employers to electronically submit required injury and illness data from their completed OSHA Form 300A. The application is accessible at the ITA webpage.
The secure website offers three options for data submission. One enables users to manually enter data into a web form, while another allows for uploading a CSV file to process single or multiple establishments simultaneously. The third option enables companies using automated record-keeping systems to transmit data electronically via an application programming interface.
The OSHA Injury Tracking Application (ITA) requires you to create an ITA account and then a Login.gov account to securely report your establishment’s injury and illness data. You must use the same email address for your Login.gov account that you use to access ITA to connect the OSHA ITA application with the account on Login.gov.
Find answers to other FAQs and instructions for entering injury and illness information in the ITA.
Always keep copies of your electronic correspondence from OSHA to demonstrate that you have met the new reporting requirement.
In this article, Gary Jones, Vice President of EHS Affairs, PRINTING United Alliance, addresses OSHA compliance. More information about OSHA can be found at Business Excellence-EHS Affairs or reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.